AML/CTF Tranche 2 reporting and records Current

Reporting and record-keeping under Tranche 2

What newly regulated firms generally need to keep and report.

Reporting entities have obligations to submit annual compliance reports in applicable circumstances and to keep AML/CTF records with a clear audit trail. The rules include scope, reporting-group arrangements, special circumstances and exemptions. This guide sets out practical points to check. It is general information, not legal or compliance advice. Vertical Flows does not file AUSTRAC reports on your firm's behalf.

Action plan

1 Check annual compliance reporting and other obligations Special cases are not automatic exemptions. AUSTRAC's overview and detailed annual-report guidance conflict on period. Don't assume one; confirm current guidance.

AUSTRAC's detailed guidance describes the annual compliance report obligation for reporting entities that provide designated services, reporting-group arrangements, special handling for some entities that closed, were sold or merged or provided no designated services during the period, and specific exemptions. Those circumstances do not automatically mean the entity is exempt; confirm the treatment that applies to your firm in AUSTRAC's current guidance. The overview and detailed annual-report page use different reporting-period wording, so this guide does not choose a period. Vertical Flows does not determine applicability or file reports on your firm's behalf.

  • Check whether your firm provided designated services and which reporting-group or special-case rules apply
  • Confirm any exemption and the applicable reporting period against AUSTRAC's detailed current guidance
  • Document how your firm identifies and escalates reportable matters

Done when: Your firm has a documented process for identifying and escalating reportable matters

AUSTRAC: annual compliance reports
2 Keep records and an audit trail Retain AML/CTF records for as long as AUSTRAC's rules require, with a clear audit trail.

Your firm needs to retain customer due diligence records, transaction records and program documentation, with a clear trail of who reviewed what and when. Vertical Flows can generate an evidence package from a completed workflow. Retention policy and duration remain your firm's responsibility.

  • Confirm your exact record-keeping duration with AUSTRAC's current guidance
  • Keep evidence, decisions and reviewer identity together, not scattered across systems
  • Make records retrievable for audit or regulator request

Done when: Records are retained in one reviewable place with a clear audit trail

See how evidence packages work